For customers Protecting your personal information Find out about our policy on privacy and data protection 1
Here at Aegon, we re committed to protecting and respecting your privacy. Looking after the personal information that we collect on our planholders and their dependants/beneiciaries, investors, scheme members, trustees and so on is our top priority and we want you to be conident that your information is in safe hands. So, we ve developed this Privacy Statement to let you know: how and why we collect personal information; what we do with it; when and why we share it with other organisations, including the types of organisations involved; how long we ll keep it for, and the rights and choices you have with regards to your personal information. The use of intermediary in this document can mean either your adviser or your intermediary, as relevant to you. Contact us If you have any questions about this notice or data protection, please contact our Data Protection Oicer. Data Protection Oicer, Aegon, Edinburgh Park, Lochside Crescent, Edinburgh, EH12 9SE Email: dataprotection@aegon.co.uk 2 Protecting your personal information
How and why we obtain personal information about you You or someone representing you, for example, your intermediary or your employer, may give us information about you by completing forms (paper versions or through our website, including our online services or social media platforms) or by contacting us by phone, email or otherwise. This includes information you provide when you: search for a product; submit an application electronically or otherwise; call us; take part in discussion boards or other forms of social media; enter a competition, promotion or survey, or when you report a problem with the website. Depending on the circumstances, the personal information we gather about you may include: your name; address; date of birth; plan number; gender; email address; phone number; inancial information; medical information, and any further personal information required as part of a product application or which you share through the website. You can ind additional information on the more common ways we collect personal information and why below: Phone calls We ll ask you for some personal details to identify you when you call us and to allow us to conirm that you re the owner or representative of the plan. We ll hold details of the call for audit and administration purposes and to enable us to facilitate the contract. The recording of the call will be kept for seven years and in line with our retention policy, so that we can meet our legal obligations when resolving complaints or legal disputes. Information obtained automatically through your use of the website and our tools (including cookies) Our website uses cookies and similar technologies such as tags and pixels to distinguish you from other users of the website. This helps us provide you with a good experience when you browse the website and also helps us to improve the website. Where selected, our website will collect and use information such as: your name, address, National Insurance number, bank details and so on to enable us to set up an Aegon Retirement Choices (ARC) account(s) or an Aegon customer dashboard account and collect payment(s); your existing savings and retirement goals, where you use our Retiready score, goals and lifestyle planner tools; your email address, password, security question and answer and phone number where you ve selected to have digital access to view your plan. Application forms Personal information is collected through our application and enrolment process (for example through our paper application forms and online) to enable us to verify your identity, allow a plan to be set up or to assess any claims that are made. We ll also use your personal information to provide ongoing administration of your plan, for example to collect and apply contributions to your plan, issue yearly statements and so on. We need this information to carry out our obligations and to provide you with the products and services under the terms of your contract with us. Without this we wouldn t be able to provide you with a plan. Protecting your personal information 3
Direct marketing If you ve given us your consent, we may use the information we ve collected about you to send you marketing ofers and news about our products and services using various channels such as mail, phone, email and SMS. We ll ask for your consent when you apply for a plan with us through our application form or when you register online. You can remove your consent at any time by writing to or sending an email to our Data Protection Oicer, or updating your preferences on your Retiready Account. We won t sell your personal information to other organisations outside of the Aegon Group for a marketing purpose. Competitions and surveys If you enter any competitions or surveys, we ll capture some personal information about you. By supplying these details you re giving us your consent to contact you to let you know if you re the winner. Your information won t be used for any other purpose and will be deleted once the winner has been announced, unless you ve consented to receiving any marketing material from us. Publicly available information We may collect and use information about you which has been made publicly available as part of our claims investigation and decision making process. We may use your information for statistical or research purposes or for testing our systems. If we do this your personal information will be anonymous so that you can t be identiied. Our data security policies mean that we hold all personal information securely and limit access to those who need to see it. We apply extra security to sensitive personal information, such as medical details, which are necessary to administer particular products, such as our Protection products. Sharing your personal information Service providers We work with carefully selected service providers that carry out certain functions on our behalf. These include companies that help us with: technology services; outbound customer communication and scanning of correspondence; banking services; administration of our protection business, and tracing of customers who we ve lost contact with. We only share the appropriate level of personal information necessary to enable our suppliers to carry out their services and we require them to keep the information safe and protected at all times. Our suppliers must only act on our instructions and can t use your personal information for their own purposes. Other organisations and third parties It s sometimes necessary to disclose your personal information or to add to it from other sources. These other sources may include past and present employers, the trustees or administrators of a trust or scheme, your intermediary or someone oicially acting on your behalf (so long as the appropriate authority is in place), as well as those described below. For example, if you re an employee in a group personal pension or group stakeholder pension scheme, and your employer would like to change the intermediary looking after the scheme, we need to share information with the new intermediary. We ll only do this if we receive written authorisation from your employer. If you have investments in a broker fund we d let that broker know your contact details so they can send you statements. Aegon Retirement Choices (ARC) If you have an ARC account(s) set up through your employer, your scheme adviser may ask us to provide them with some information about you and your ARC account(s). 4 Protecting your personal information
This is the information given to us to set up and administer your ARC account(s) with Aegon, together with a list of the investments you hold under your ARC account(s) and their value. We ll only share information where: we have an agreement with the scheme adviser to do this; the scheme adviser is providing additional service(s) that may be of beneit to you in relation to your ARC account(s) with Aegon, and you haven t opted out of this. Some examples of these additional services are: overall scheme design; tailored pension planning for you, for example by reference to your age, contributions, fund value and retirement date; advice on pension areas which may be relevant to you such as the lifetime allowance or the annual allowance; communications to you by the scheme adviser about your ARC account(s), and bespoke inancial services such as retirement seminars based on your age, contribution level, guidance and investment reviews, to make sure you re still on target to meet your retirement goals. The scheme adviser is the person who advises your employer. Employer is the person (including a company or other legal entity) that employs you and gives you initial access to your ARC account(s). This includes any subsequent person who employs you and who ofers you access to the service we provide to you and your adviser to manage your investments in your plan(s). This will continue if you leave this employer unless you tell us otherwise. You can tell us any time if you don t want us to do this by contacting us at: Platform Client Services Aegon Edinburgh Park Edinburgh EH12 9SE Phone: 0345 680 1234, Monday to Friday, 9am to 5pm Email: clientservices@arc.aegon.co.uk Financial crime prevention We may disclose your information to licensed credit reference and/or fraud prevention agencies to help make inancial or insurance proposals and claims decisions (this will be during the application or enrolment process and on an ongoing basis), for you and anyone you re linked with inancially or other members of your household. Our enquiries or searches may be recorded and credit reference agencies may supply us with inancial information. We may also use these agencies to complete checks that are designed to verify your identity or bank details. To protect insurers like ourselves and, ultimately, customers and customers payments against fraudulent claims and crimes such as money laundering, we and other insurers use information exchange registers to share information. When we re dealing with applications we may search these registers. If a claim is made under your plan, information about you (including details provided on the application and claim form) will be put on the registers so that other insurers can see them if necessary. If false or inaccurate information is provided and fraud is identiied, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when: checking details on applications for credit and credit related or other facilities; managing credit and credit related accounts or facilities; recovering debt, and checking details on proposals and claims for all types of insurance. Please contact the Data Protection Oicer if you d like to receive details of the fraud prevention agencies used by Aegon UK. We and other organisations may access and use the information recorded by fraud prevention agencies from other countries. Protecting your personal information 5
Sharing of special categories of personal information, for example medical information If we request medical information from you or a medical practitioner who has cared for you or from other insurers, this will be suiciently protected. We may ask for information from other insurers or medical practitioners to check, clarify or expand answers you ve given us for example, on a claim or application. So that we can administer your plan, we may need to give your information to others who are, in turn, providing us with information about you, such as reinsurers, medical practitioners, private investigators and healthcare management companies, and access to this type of information is restricted. Additional data sharing obligations Other than the circumstances detailed above, we won t disclose your personal information to any third parties, except: to the extent that we re required to do so by law, by a government body or by a law enforcement agency, or for crime prevention purposes (including inancial crime protection and credit risk reduction); when protecting your interests or the interests of other individuals or for reasons of substantial public interest; in connection with any legal proceedings (including prospective legal proceedings); in order to establish or defend our legal rights; in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or if we, or substantially all of our assets, are acquired by a third party, we may disclose your personal data to that third party in connection with the acquisition. With your consent, we would also share your information with the Financial or Pensions Ombudsmans or other appropriate persons if the need arises. Personal information processed outside of the European Economic Area (EEA) The personal information that we collect may be transferred to, and stored at a destination outside the European Economic Area (EEA), in connection with the above purposes. This could be to other companies within the Aegon Group or to service providers working on our behalf. Where any such processing takes place, appropriate controls, such as the adoption of agreements containing the appropriate standard clauses, are in place to ensure that your information is protected to the same standard as if it were in the UK. Retention of personal information In most circumstances, we ll keep your personal information for the lifetime of your plan or product and up to seven years after your relationship with us ends, for example, if you move your plan to another provider or you settle your beneits. This is to ensure that we comply with our retention obligations, as set out by the Financial Conduct Authority (FCA) and other regulatory and legislative requirements. In very limited circumstances, we re required to keep some speciic information for longer, for example, pension transfer information, but we regularly review our retention obligations to ensure we don t keep personal information longer that we re legally obliged to. Your rights You have a number of rights under the Data Protection laws, including: the right to request a copy of the personal information we hold on you. When you request this information, this is known as making a Subject Access Request (SAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee; the right to have personal information we hold about you transferred securely to another service provider in electronic form; the right to have any inaccurate personal information corrected; 6 Protecting your personal information
the right to have any out of date personal information deleted once there s no business need or legal requirement for us to hold it; the right to object or restrict some processing, in limited circumstances and only when we don t have legitimate grounds for processing your personal information; the right to object to your personal information being used to send you marketing material. As mentioned above, we ll only send you marketing material where you ve given us your consent to do so. You can remove your consent at any time, and the right to ask for a decision to be made manually, where a decision is made using automated means and this adversely impacts you. Automated decision-making tools Where you apply for one of our protection products, for example critical illness, we ll use an automated decision-making tool during the underwriting process. We ve built rules into our underwriting engine which will either generate an automated decision or refer to one of our underwriters. We can manually review decisions if requested. To exercise any of these rights, please contact our Data Protection Oicer. Making a complaint If you believe we haven t processed your personal information in accordance with our Data Protection obligations, and that you ve been afected by our non-compliance, you can make a complaint to us by contacting our Data Protection Oicer. You also have the right to ask us to escalate your complaint to our Group Data Protection Oicer if you don t think it s been handled appropriately. If you re not satisied with our response, you can raise a complaint with the Information Commissioner s Oice, the UK s independent authority set up to enforce the Data Protection Regulations. You can contact them by visiting www.ico.org.uk/global/ contact-us/ Protecting your personal information 7
aegon.co.uk @aegonuk Aegon UK Aegon UK Aegon is a brand name of both Scottish Equitable plc (No. SC144517) registered in Scotland, registered oice: Edinburgh Park, Edinburgh EH12 9SE, and Cofunds Limited, Registered in England and Wales No.3965289, registered oice: Level 43, The Leadenhall Building, 122 Leadenhall Street, London, EC3V 4AB. Both are Aegon companies. Scottish Equitable plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Cofunds Limited is authorised and regulated by the Financial Conduct Authority. Their Financial Services Register numbers are 165548 and 194734 respectively. Retiready and Aegon are brand names of Scottish Equitable plc (No. SC144517) and Aegon Investment Solutions Ltd (No. SC394519) registered in Scotland, registered oice: Edinburgh Park, Edinburgh, EH12 9SE. Both are Aegon companies. Scottish Equitable plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Aegon Investment Solutions Ltd is authorised and regulated by the Financial Conduct Authority. Their Financial Services Register numbers are 165548 and 543123 respectively. 2017 Aegon UK plc GEN06774 12/17